IN THE NEWS

Mar 22, 2023
ABA

ABA Section of Civil Rights and Social Justice: Chair Chat with Lauren Stiller Rikleen

ABA Section Chair Juan R. Thomas and Rikleen Institute for Strategic Leadership President & Founder and Lawyers Defending American Democracy Executive Director Lauren Stiller Rikleen discuss 'Her Honor – Stories of Challenge and Triumph from Women Judges' and Women’s History Month.

Mar 14, 2023
MSNBC

The Last Word With Lawrence O’Donnell

Using excerpts from LDAD’s ethics complaint as the basis for discussion, Lawrence O’Donnell and his guests, Professor Stephen Gillers and attorney Neal Katyal, engaged in a substantive and thoughtful conversation that clearly explained why the allegations against Mr. Passantino matter to the rule of law. The discussion of LDAD’s ethics complaint begins at 5:53 into the segment.

featured press
Mar 13, 2023
New York Sun

Proposed Ethics Code for Supreme Court Escalates Campaign To Bind the Justices

The release of a “Model Code of Conduct for U.S. Supreme Court Justices” by two good-government groups — Project for Government Oversight and Lawyers Defending Democracy — brings into sharp focus the growing effort to regulate the justices, a push that the Nine has thus far resisted.

Mar 13, 2023
Washington Examiner

Clarence and Ginni Thomas could be sidelined under Supreme Court 'model' ethics code

A proposal by outside interest groups for the Supreme Court to adopt a new "model" ethics code could thrust Justice Clarence Thomas and his spouse, Ginni, further into the political limelight. The proposed guidelines from so-called independent government watchdogs Project on Government Oversight and LDAD would put in place "more stringent guidelines for recusal." 
 

Mar 6, 2023
Newsweek

Trump Attorney Could Face Disbarment Over Cassidy Hutchinson Testimony

A group of three dozen attorneys affiliated with the center-left organization Lawyers Defending American Democracy filed a complaint with the Washington, D.C., bar on Monday, accusing Stefan Passantino of pressuring Cassidy Hutchinson to provide false testimony to members of Congress.

Mar 6, 2022
Salon

Ex-Trump ethics lawyer may face disbarment for allegedly trying to influence Hutchinson testimony

Hutchinson, who was a top aide to former White House chief of staff Mark Meadows, provided damning information during the House committees January 6 probe and revealed that her previous lawyer, Stefan Passantino, had tried to influence her testimony and encouraged her to withhold information from the committee.

Mar 6, 2023
Law360

Fmr. Bar Heads Want Ex-WH Atty Disbarred Over Jan. 6 Probe

A group of past District of Columbia and American Bar Association presidents on Monday joined calls for the disbarment of former Trump White House attorney accused of urging a staffer to lie to Congress.

Mar 6, 2023
ABA Journal

First lawyer who advised Jan. 6 witness Cassidy Hutchinson should face ethics probe, group tells regulators

Hutchinson had testified that Passantino, a former lawyer in the White House counsel’s office, told her to downplay her knowledge of events before the attack and told her that: “The less you remember, the better,” according to prior coverage by Reuters, which obtained a transcript of the testimony.

Mar 6, 2022
New York Times

Group Seeks Disbarment of a Trump-Aligned Lawyer for a Key Jan. 6 Witness

Prominent lawyers filed a scathing ethics complaint against Stefan Passantino, who represented Cassidy Hutchinson in the early stages of the House committee’s investigation.

 

Nov 8, 2022
Bloomberg Law

Federalist Society’s Influence on Courts Is Bad for Democracy

Peggy Quince and Lauren Stiller Rikleen of Lawyers Defending American Democracy examine the Federalist Society’s influence over state and federal judicial selection. They say originalist judges are problematic for democracy by looking to what the framers would have done.

Oct 12, 2022
New York Times

Lawyers Group Asks Court to Punish an Author of Trump Electors Scheme

An ethics complaint in New York against Kenneth Chesebro is the latest example of legal troubles for lawyers who helped Donald J. Trump try to overturn the 2020 election.

Oct 12, 2022
Reuters

Lawyer group says Trump attorney broke ethics rules in fake elector plan

A group of prominent attorneys on Wednesday asked attorney regulators in New York to investigate lawyer Kenneth Chesebro in connection with former U.S. President Donald Trump's efforts to overturn his 2020 electoral loss to Joe Biden.

Aug 26, 2022
USA Today

Will Pentagon whistleblower Yevgeny Vindman retire as colonel?

Supporters of Army Col. Yevgeny “Eugene” Vindman are urging the White House to allow the Pentagon whistleblower to retire at his current rank when he retires Wednesday, acknowledging unfair treatment which he has received in recent years.

Aug 26, 2022
Military Times

Will Pentagon whistleblower Yevgeny Vindman retire as a colonel?

Both Vindman brothers have become politically polarizing figures since Trump’s first impeachment trial, where the former president was ultimately acquitted of charges that he pressured Ukrainian President Volodymyr Zelenskyy in 2019 to help with political attacks against Biden in exchange for foreign aid.

Aug 26, 2022
The Hill

Biden faces calls to let Vindman twin retire as colonel

President Biden is facing calls to allow Col. Yevgeny “Eugene” Vindman, who alongside his twin brother Alexander blew the whistle on former President Trump’s July 2019 call with Ukrainian President Volodymyr Zelensky, to retire with the title of colonel. 

Aug 23, 2022
Washington Post

Opinion: Liz Cheney is a smart, brave Republican

Gary Ratner, LDAD's co-founder, authors an opinion piece repudiating Republican Florida state Rep. Anthony Sabatini assertion that Liz Cheney is not "smart" for speaking out against former president Donald Trump’s Big Lie.

Aug 23, 2022
Houston Chronicle

Paxton is pushing for dismissal of bar lawsuit

Lawyers for Texas Attorney General Ken Paxton will argue Wednesday in court that a judge should drop a disciplinary case filed against him by the State Bar of Texas alleging he knowingly lied and attempted to mislead the U.S. Supreme Court in an effort to overturn the 2020 election results.

Aug 9, 2022
National Law Journal

Justice Alito’s Hypocrisy

Religious liberty means that all religions are able to thrive in harmony. It does not mean that a majority of SCOTUS justices who share a religion should be able to demand that other religions subjugate their own beliefs to the majority’s will.

July 22, 2022
CNN

Opinion: Why Steve Bannon's conviction really matters

Even though Bannon's conviction is for contempt, rather than for an underlying crime, the principle remains the same. For more than two centuries, America has been a society bound by the rule of law, not the rule of men -- and we need to keep it that way.

July 22, 2022
CNN

Opinion: Why Steve Bannon's conviction really matters

Even though Bannon's conviction is for contempt, rather than for an underlying crime, the principle remains the same. For more than two centuries, America has been a society bound by the rule of law, not the rule of men -- and we need to keep it that way.

July 20, 2022
The Bulwark

Trump’s Inexcusable Jan. 6th “Dereliction of Duty”

“Dereliction of duty” is a serious accusation, and based on what has already emerged in the committee’s hearings, one that fits. It is beyond question that President Trump was aware in real time of the violence at the Capitol and that he did nothing for hours on end to call off the mob he had helped to summon. So argues, our colleagues Dennis Aftergut and Eugene Fidell.

June 30, 2022
Global News

Controversial rulings spawn questions about U.S. Supreme Court's legitimacy

From its historic rollback of abortion rights to limiting regulations on power plants' carbon dioxide emissions, the U.S. Supreme Court is stirring up controversy and anger. LDAD's Lauren Rikleen weighs in.

June 30, 2022
Bloomberg Law

The Politicization of SCOTUS Threatens Its Legitimacy

Prior to this term, Americans mostly were comfortable with the idea that the US Supreme Court would ensure their constitutional rights were protected against government overreach, say James F. McHugh and Lauren Stiller Rikleen of Lawyers Defending American Democracy. 

May 3, 2022
Bloomberg Law

SCOTUS Draft Rejecting Roe Must Spur Legal Profession to Speak Up

The unprecedented leak of an apparent draft opinion from the U.S. Supreme Court indicating it is poised to overturn Roe v. Wade should be a wake-up call to the legal profession, says leadership consultant Lauren Stiller Rikleen. Sitting on the sidelines is no longer an option, she writes, as the fundamental right of women to make decisions affecting their own bodies is at risk.

Mar 8, 2022
Houston Chronicle

Texas State Bar Complaint Moves Forward Against AG Ken Paxton 

This Houston Chronicle article provides an update regarding the status of a complaint filed by Lawyers Defending American Democracy and 16 Texas lawyers in July, 2021.

Mar 7, 2022
National Law Journal

Russian Attack on Kyiv Holocaust Memorial Site a Blatant Violation of International Law

It is particularly painful to watch not only war crimes committed by the Russian assault on the Ukrainian people, but the return in the 21st century of an unjustified attack in a region where civilians have endured a history of ethnic cleansing, mass casualties, and genocide.

Mar 2, 2022
National Law Journal

SCOTUS Confirmation Should Focus
on Qualifications

The country deserves a confirmation process for Judge Jackson that is incisive and informative. Americans will have a crucial opportunity to watch the interplay of difficult dynamics that include politics, bias, and entrenched institutions.

Feb 14, 2022
Bloomberg Law

Entrenched Biases Surface for Potential SCOTUS Nominee

Deep-seated biases are evident in commentary questioning whether President Biden’s vow to appoint a Black woman to the U.S. Supreme Court conflicts with finding the most qualified jurist for the role, says leadership consultant Lauren Stiller Rikleen.

January 7, 2022
National Law Journal

Democracy Is Backsliding — The Rule of Law in Decline

Data shows that our democracy is “backsliding” and our rule of law is in decline. Yet our nation’s lawyers—the profession most trained to help—largely remain on the sidelines instead of taking a stance.

Dec 17, 2021
The Hill

Legal organization files ethics complaint on Trump lawyer Eastman

A legal organization filed an ethics complaint on Thursday seeking to have a lawyer, John Eastman, investigated for advising former President Trump in efforts to overturn the 2020 election results. 

Dec 17, 2021
Newsweek

1,300 Attorneys Demand Calif. Bar Investigate Trump Lawyer Over Effort to Overturn Election

Eastman wrote a now infamous memo that suggested then-Vice President Mike Pence had the authority to reject electors from key battleground states that flipped blue for President Joe Biden, resulting in Trump's Electoral College loss.

Dec 17, 2021
Above the Law

Bumbling Trump Coup Lawyer John Eastman Finds Yet Another Bar Complaint In His Stocking

The petitioners claim that Eastman’s effort to subvert the will of the voters amounts to a violation of California Rule of Professional Conduct 8.4(c), which prohibits a lawyer to “engage in conduct involving dishonesty, fraud, deceit, or reckless or intentional misrepresentation.”

Dec 16, 2021
Bloomberg News

Trump Lawyer Eastman Should Be Sanctioned, 1,200 Attorneys Say

A lawyers’ group has filed the third ethics complaint against Trump lawyer John Eastman with the California bar, alleging misconduct when he colluded with others in attempting to overturn the results of the 2020 presidential election and keep Donald Trump in office for a second term.

Dec 16, 2021
Law.com

1000 Attorneys Ask California Bar to Investigate Trump Ally John Eastman

More than 1,300 signers in nearly all 50 states and the District of Columbia have signed in support of the complaint, which asks the State Bar of California to investigate and, if appropriate, sanction Mr. Eastman for violations of the California Rules of Professional Conduct.

Dec 16, 2021
Law & Crime

Legal Group Files Bar Complaint Against John Eastman for ‘Carefully Orchestrated’ Effort to ‘Overturn the Results’ of the 2020 Election

A legal group filed a bar complaint against conservative attorney John Eastman on Thursday claiming he violated legal ethics rules while serving as an attorney for former President Donald Trump.

Nov 22, 2021
ABA Journal

Lawyers call on members of the profession to defend voting rights

“We’re lawyers. If we’re not speaking up for this issue, who will?” says Lauren Stiller Rikleen of Lawyers Defending American Democracy, a group pushing for more attorneys and firms to take action against the restrictions. 

Oct 18, 2021
Bloomberg Law Opinion

Disciplinary Complaints Await Former Assistant AG Jeffrey Clark

Bloomberg Law has published an op-ed by LDAD steering committee members James McHugh, John Montgomery, and interim Executive Director Lauren Rikleen. The piece considers the fate of former Acting Assistant Attorney General Jeffrey Clark, who is the target of LDAD's most recent ethics complaint.

Oct 17, 2021
The Guardian

Pressure mounts on ex-DoJ official Jeff Clark

Jeffrey Clark, a former top environmental lawyer at the Trump justice department accused of plotting with Trump to undermine the 2020 election results in Georgia and other states, is facing ethics investigations in Washington that could lead to possible disbarment, as well as a watchdog inquiry that might result in a criminal referral.

Oct 5, 2021
The Hill

Group asks DC court to investigate DOJ official who peddled false election claims

A group of legal heavyweights on Tuesday asked the disciplinary panel of the D.C. Court of Appeals to investigate a former Department of Justice (DOJ) official who allegedly sought to use his official position in the federal government to overturn former President Trump’s election defeat.

Oct 5, 2021
Reuters

Attorneys file ethics complaint against ex-Justice official over plot to help Trump

A group of prominent attorneys on Tuesday filed an ethics complaint against Jeffrey Bossert Clark, a former top Justice Department official who is under investigation for allegedly plotting to help former President Donald Trump overturn the 2020 presidential election.

Oct 5, 2021
National Law Journal

Trump DOJ's Civil, Enviro Leader Faces DC Ethics Complaint

The former head of the U.S. Department of Justice's civil and environment divisions during the Trump administration should face serious sanctions for his "extraordinary" and "unethical" conduct during the 2020 presidential election.

Oct 5, 2021
Above the Law

Trumpland Lawyers Face Bar Complaints After Engaging In Some Light Coup-ing

In DC, a group called Lawyers Defending American Democracy demands accountability for Jeffrey Clark, who attempted to persuade his bosses to send a letter to election officials in Georgia — and then the rest of the swing states — urging them to let the legislature override the will of the voters.

Aug 31, 2021
Law 360

Texas Bar Launches New Investigation Of Paxton Election Suit

The State Bar of Texas has agreed to investigate Attorney General Ken Paxton after four former state bar presidents complained that his support of a lawsuit to overturn the 2020 presidential election should prevent him from practicing law in the state.

Aug 30, 2021
Law & Crime

State Bar of Texas Investigating AG Ken Paxton Over Alleged Ethics Violation

The State Bar of Texas has agreed to investigate an ethics complaint filed against Texas Attorney General Ken Paxton (R). In a letter, the Office of Chief Disciplinary Counsel of the State Bar of Texas told complainant Gershon Gary Ratner, co-founder of LDAD, that his late July ethics complaint–filed along with 15 other Lone Star State attorneys–contained facts alleging that Paxton had engaged in professional misconduct.

Aug 30, 2021
The Texas Tribune

Texas State Bar Examining Paxton Misconduct Claim

A group of 16 lawyers who filed an ethics complaint against Attorney General Ken Paxton said Monday that the state bar was looking into its professional misconduct claim against the sitting attorney general. The group includes four former presidents of the State Bar of Texas and was organized by the group Lawyers Defending American Democracy.

July 26, 2021
Houston Chronical

Editorial: Past presidents of Texas State Bar want AG Paxton disbarred.

A 31-page complaint was filed last week with the State Bar of Texas by 16 Texas attorneys, including four past presidents of the State Bar of Texas, as well as legal scholars and legal-ethics experts.

July 22, 2021
Newsweek

Ethics Complaints Filed Against Texas AG Ken Paxton for Efforts to Overturn 2020 Election

Gershon Ratner, co-founder of LDAD, explained the lawsuit did not have "standing," as the Supreme Court inevitably determined. Ratner described Paxton's lawsuit as "a prescription for an autocratic president to perpetuate his power indefinitely against the will of the voters."

July 22, 2021
The Crime Report

TX Lawyers Call for Disbarment of ‘Unethical’ AG Paxton

Sixteen Texas lawyers, including four former State Bar of Texas presidents, have filed a complaint urging bar regulators to suspend or permanently disbar Texas Attorney General Warren Kenneth Paxton Jr. from practice.

July 22, 2021
ABOVE THE LAW

TX Attorney General Ken Paxton Files Fake Election Suit, Gets Real Bar Complaint

Texas Attorney General Ken Paxton has bigger problems than a bar complaint. Most notably, he’s under indictment for securities fraud and is facing a whistleblower allegations from his own staff that he took bribes and abused his office. And still, demands for your ouster from the legal profession by 31 eminent professionals, including four past presidents of the state bar, is never a good look.

July 21, 2021
LAW.COM

High-Profile Group of Lawyers Seeks to Suspend or Disbar Texas AG Ken Paxton

Asserting Paxton has brought “dishonor” to his fellow Texas lawyers and the legal profession, the group of 16 prominent Texas lawyers and the group Lawyers Defending American Democracy said in the complaint that Paxton has engaged in a pattern of “serious violations” of the Texas Disciplinary Rules of Professional Conduct.

July 21, 2021
LAW360

Past Texas Bar Presidents Want AG Paxton Reprimanded

Four former presidents of the State Bar of Texas are part of a group of lawyers who on Wednesday urged the bar to reprimand Attorney General Ken Paxton for attempting to overturn presidential election results and allegedly encouraging participation in the Jan. 6 Captiol riot.

July 12, 2021
The Hill

Lawyers group criticizes Noem, Abbot on National Guard to border

A nonpartisan group of lawyers released a statement on Monday in opposition to the deployment of non-federalized National Guard troops to the border by South Dakota Gov. Kristi Noem (R) and Texas Gov. Greg Abbott (R), concluding that the states are “way out of their lane.”

July 13, 2021
Above the Law

Private National Guard Field Trips To The Border May Be Useless But At Least They’re Also A Constitutional Crisis!

If privately funded commandeering of the armed forces to enforce Tucker Carlson’s fever dreams sounds like a dystopian nightmare, then you are paying the appropriate amount of attention. Lawyers Defending American Democracy thinks this is a problem too, highlighting the disturbing conceit that patrolling an international border is “state” business as opposed to a federal prerogative with massive foreign policy implications.

June 26, 2021
NBC News

Rudy Giuliani's New York suspension proves dangers of Trump's lies

Giuliani’s troubles with the appellate division of the Supreme Court of New York began last January, when [...] Lawyers Defending American Democracy, presented a detailed complaint alleging that Giuliani “knowingly propagated a false narrative of election fraud to delegitimize ... Biden’s presidential victory and to undermine public confidence in the national electoral process.”

June 24, 2021
Courthouse News Service

Giuliani’s Law License Suspended in NY for Pushing Voter-Fraud Lie

A group of attorneys called Lawyers Defending American Democracy called on a New York disciplinary panel to immediately suspend Giuliani’s law license pending an investigation.

Giuliani’s claims of widespread voter fraud in the 2020 election have landed him as a co-defendant in multiple defamation cases[.]

June 19, 2021
Boston Globe Letters

Legal profession was stunningly silent, even complicit, in face of Trump’s assaults

Too few lawyers have entered the fray to protect and defend the rule of law, let alone critique or hold accountable lawyers and elected officials who participated in the corruption of the Justice Department and the efforts to nullify the results of the 2020 election.

June 18, 2021
National Law Journal

'No Exception': Lawyers Ask DC Ethics
Board to Force Review of Barr Complaint

“Gross misconduct by members of the bar — be they private attorneys or the Attorney General of the United States — seriously stains the reputation of the legal profession with the general public, and also, no doubt, tempts other lawyers to skirt ethical boundaries."

Apr 7, 2021
Bloomberg Law

Law Firms Mostly Quiet in Fight Over Georgia Voting Rights

As corporate leaders continue a public pressure campaign against changes to Georgia’s voting law that have sparked a national debate, the country’s largest law firms so far are staying on the sidelines.

Apr 7, 2021
Law 360

Open Letter Encourages Lawyers To Protect Voting Rights

Lawyers should use their powerful and influential platforms to advocate for the protection of the rule of law and to fight against voter suppression efforts in the United States, according to an open letter signed by Paul Weiss’ chairman and hundreds of other attorneys.

Apr 7, 2021
law.com

National Group Calls on Legal Profession to Fight Voter Suppression

The national organization Lawyers Defending American Democracy has issued an Open Letter calling on law firms, bar associations and law schools to devote resources to protecting and expanding voter rights in the midst of efforts in state legislatures around the country to curtail access to the polls, including new restrictions passed in the state of Georgia.

Mar 4, 2021
NYC Bar Association Podcast

The Professional Disciplinary Complaints about the Conduct of Rudolph Giuliani

Jennifer Rodgers, member of the City Bar’s Task Force on the Rule of Law and CNN legal analyst, speaks with Christine Chung, a trial and appellate attorney, former federal prosecutor and steering committee member of Lawyers Defending American Democracy about disciplinary complaints against Rudy Giuliani.

Mar 3, 2021
law.com

NYC Bar Details Complaints, Calling for ‘Full’ Attorney-Discipline Investigation of Giuliani

The complaints against Mr. Giuliani allege serious misconduct,” said the city bar association in an 11-page report, and they “appear to be substantiated by extensive evidence—consisting in large part of Mr. Giuliani’s own statements.

Mar 2, 2021
Law 360

NYC Bar Supports Giuliani Probe Over Work For Trump

The New York City Bar Association backs separate ethics complaints filed in January by former New York State Bar Association president Michael Miller and by the bipartisan nonprofit Lawyers Defending American Democracy that contend Giuliani intentionally and repeatedly crossed ethical and legal lines.

Mar 3, 2021
law.com

NYC Bar Details Complaints, Calling for ‘Full’ Attorney-Discipline Investigation of Giuliani

The complaints against Mr. Giuliani allege serious misconduct,” said the city bar association in an 11-page report, and they “appear to be substantiated by extensive evidence—consisting in large part of Mr. Giuliani’s own statements.

Feb 28, 2021
law.com

‘Boldly Frivolous’ Gohmert v. Pence Election Lawsuit Spurs Bar Complaints Against Attorneys

“Not a single word in that amendment, or in any other, gives the vice president any role whatsoever in choosing which votes to count let alone the extraordinary, unilateral power to select who the next president should be, regardless of the outcome of votes in the various states,” the group said in a statement in January.

Feb 19, 2021
The Fulcrum

One vote both squandered and sullied the ultimate congressional check on a president

Donald Trump tried to steal the election and prevent the peaceful transfer of power. And 43 Republican senators said that’s OK when they voted to acquit him in the impeachment trial. It was time to “stop the steal,” as the former president’s allies so often shout. But it was the Senate that refused.

Feb 19, 2021
ABA Journal

How lawyers can honor Black History Month with action

This February, we mark Black History Month at a time of sharpened focus on institutional racism, the Black Lives Matter movement and a raging pandemic that has disproportionately impacted minority communities. Read the latest opinion piece by LDAD committee member Lauren Stiller Rikleen.

Feb 1, 2021
New York Daily News

More than 3,100 lawyers call for Rudy Giuliani’s law license to be revoked

More than 3,100 lawyers, including a former Attorney General, 14 ex-federal judges and three dozen former prosecutors at the office Rudy Giuliani once led, have joined a call for his law license to be revoked.

Jan 22, 2021
Law 360

Attys Go After Giuliani’s Law License Over Campaign Tactics

New York State Bar Association leaders and academics hit Rudy Giuliani with an ethics complaint Thursday, joining others in calling on the bar to suspend the former New York City mayor’s license and investigate potential professional violations for persistently touting false voter fraud claims while spearheading ex-President Donald Trump’s efforts to overturn the 2020 election results.

Jan 21, 2021
The New York Times

Prominent Lawyers Want Giuliani’s Law License Suspended

Dozens of prominent lawyers have signed a formal complaint seeking the suspension of Rudolph W. Giuliani’s law license — the latest and loudest in a series of calls to censure him for his actions as President Donald J. Trump’s personal attorney.

Jan 21, 2021
The Hill

Lawyers group calls for Giuliani’s suspension from law practice, ethics probe

A national lawyers group on Thursday filed an ethics complaint against Rudy Giuliani that asked a New York court panel to suspend the Trump ally’s law license and undertake a review of his role in promoting false election fraud claims that some argue fueled the insurrection at the Capitol.

Jan 21, 2021
Forbes

Ethics Complaint Against Rudy Giuliani Seeks To Disbar Him In New York

A legal advocacy group called Thursday for Rudy Giuliani to be investigated and potentially lose his license to practice law, filing an ethics complaint against the attorney with the Grievance Committee of the New York State Bar after the former New York City mayor led former President Donald Trump’s legal campaign to overturn the election and pushed baseless election fraud claims.

Jan 21, 2021
Washington Post

Lawyers want Giuliani investigated, license suspended

A lawyers’ group filed an ethics complaint against Rudy Giuliani with New York’s courts, calling for him to be investigated and his law license suspended over his work promoting former President Donald Trump’s false allegations over the 2020 election.